1. Plaintiff David McKee, M. D. , for his Complaint against Defendant Dennis Laurion, states and alleges as follows: Plaintiff McKee is a medical doctor licensed to practice medicine in the State of Minnesota, resides and works in Duluth, St. Louis County, Minnesota, and practices neurology in Duluth, St. Louis County, Minnesota.

2. Defendant Laurion is an individual who resides in Duluth, St.Louis County, Minnesota.

3. On or about April 20, 2010, Plaintiff McKee furnished medical services to a relative of Defendant. On or about April 22, 2010, Defendant Laurion published to third parties on the worldwide internet various false statements of fact concerning Plaintiff’s treatment of a relative of Defendant (relative of Defendant is sometimes hereinafter referred to as “the individual”). The false statements of fact include, but are not limited to, the following: that Plaintiff “seemed upset” that the individual had been transferred from an ICU (intensive care unit) to a ward room; that Plaintiff stated to the individual that he had to “spend time finding out if you were transferred or died;” that he further stated that “44% of hemorrhagic strokes die within 30 days. I guess this is the better option;” and he told the individual that “you don’ t need therapy;” that he told the individual that “it doesn’t matter” that the gown was hanging from the neck, without any back ; that Plaintiff strode out of the room without talking to the individual’s wife or Laurion; that he subsequently stated that “Dr. McKee is a real tool!”

4. On or about April 22, 2010, Defendant further published additional false statements to various third parties, including, but not limited to, the American Academy of Neurology; the American Neurological Association; two physicians in Duluth; the Lake Superior Medical Society; the Minnesota Quality Improvement Organization; Office of Quality Monitoring of the Joint Commission; the Patient’s Action Network of the American Medical Association; St. Louis County Public Health & Human Services Advisory Committee; Senior Ombudsman; St. Luke’ s Hospital; Minnesota Department of Health Office of Health Facility Complaints; and , Minnesota Medical Association.

5. The statements made to these individuals included some of the same statements as in other communication set forth in Paragraph 3, above, as well as additional false factual statements, including that Plaintiff “blamed” the patient for loss of Plaintiff’s time; when he exited the room where Defendant’ s relative was located , Plaintiff was “scowling,” that Plaintiff regarded Defendant’s relative as a “task and a charting assignment;” that he did not treat Defendant’s relative with “dignity.”

COUNT I. DEFAMATION

6. Plaintiff restates and re-alleges the above as if fully set forth herein and further states as follows:

7. The aforesaid statements cause harm to the reputation of Plaintiff insofar as it has a tendency to lowers his regard in the eyes of others.

8. The aforesaid conduct constitutes defamation per se.

9. As a result of the above, Plaintiff has suffered damages, including harm to reputation, emotional distress, pain and suffering, in a reasonable amount in excess of $50,000.

10. By reason of the foregoing, Plaintiff is entitled to judgment against Defendant in an amount in excess of $50,000.

COUNT II. INTERFERENCE WITH BUSINESS

11. Plaintiff restates and re-alleges the above fully set forth herein and further states as follows:

12. The aforesaid conduct by Defendant was done intentionally, knowingly, and without authorization.

13. The aforesaid conduct by Defendant interferes with Plaintiff s business activities.

14. As a result of the above, Plaintiff has suffered damages, including potential loss of income , emotional distress, pain and suffering in an amount in a reasonable amount in excess of $50,000.

15. For the foregoing reasons, Plaintiff is entitled to judgment against Defendant in a reasonable amount in excess of $50,000.

WHEREFORE, Plaintiff David McKee requests the following relief against Defendant Dennis K. Laurion:

1. A judgment in a reasonable amount in excess of $50 ,000 for defamation.

2. A judgment in a reasonable amount in excess of $50,000 for interference with business.

3. Leave to amend the Complaint to include a claim for punitive damages.